Computer Science Department Carnegie Mellon University Pittsburgh, PA 15213-3891 February 6, 2001 Mr. Hemanshu Nigam Director, Worldwide Internet Enforcement Motion Picture Association 15503 Ventura Boulevard Encino, CA 91436 Dear Mr. Nigam: I write in response to your email of yesterday, in which you allege that I am illegally providing a "circumvention device" as defined in 17 USC 1201(a)(2). The only URL given in your complaint was http://www.cs.cmu.edu/~dst/ which is the address of my personal home page. I understand that you are not objecting to my entire home page, but rather, to certain portions of it that deal with DeCSS. However, you neglected to specify the files that you object to. If you visit my "Gallery of CSS Descramblers" at http://www.cs.cmu.edu/~dst/DeCSS/Gallery you will find the DeCSS code in several dozen forms. The C source code is there, naturally. But the same ideas are also expressed in many other forms, including: translations of the algorithm into Scheme, and Standard ML of New Jersey http://www.cs.cmu.edu/~dst/DeCSS/Gallery/css_descramble.scheme http://www.cs.cmu.edu/~dst/DeCSS/Gallery/anonymous-code.sml translation into a C-like language that is not C (and for which no compiler currently exists, so the file is not compilable) http://www.cs.cmu.edu/~dst/DeCSS/Gallery/new-language.txt a line-by-line translation of the C code into English, done by myself http://www.cs.cmu.edu/~dst/DeCSS/Gallery/plain-english.html a line-by-line English translation, in which the original C source code has been interspersed with the equivalent English statements http://www.cs.cmu.edu/~dst/DeCSS/Gallery/english-and-c.html a translation of the C code into English, done automatically by a Perl program, along with another Perl program that can translate the English back into C automatically http://www.cs.cmu.edu/~dst/DeCSS/Gallery/css-auth.eng.txt a perfectly legible PICTURE of the C source code (three GIF files) http://www.cs.cmu.edu/~dst/DeCSS/Gallery/page1.gif http://www.cs.cmu.edu/~dst/DeCSS/Gallery/page2.gif http://www.cs.cmu.edu/~dst/DeCSS/Gallery/page3.gif a photograph of a t-shirt on which the C source code is printed http://www.cs.cmu.edu/~dst/DeCSS/Gallery/tshirt_back.jpg an audio recording of a person reading the English version of the source code aloud http://www.cs.cmu.edu/~dst/DeCSS/Gallery/css_descramble.mp3 an audio recording of a person singing the source code, with guitar and drum accompaniment http://www.cs.cmu.edu/~dst/DeCSS/Gallery/css_descramble_joe_wecker.mp3 There are numerous other forms as well, which you can see for yourself if you visit the Gallery. In addition, there is a section devoted to the cryptographic research of Frank Stevenson, including essays and several small C programs Mr. Stevenson wrote that illustrate his ideas. You can find a listing of the various files here: http://www.cs.cmu.edu/~dst/DeCSS/FrankStevenson/index.html In order for me to consider the allegation you raised in your letter, I request that you specify the URL for each of the files on my web site to which you are objecting, and for each such file, give the legal basis for your objection. It would also be helpful if you would explain, for those representations of the DeCSS algorithm to which you do not object (such as, perhaps, the recording of someone singing the source code), why you do not object to my publishing the algorithm in that particular form. Finally, I think I should mention that the Gallery of CSS Descramblers is by now a well-known academic work. You will find on the main Gallery page two dozen press clippings of articles that mention the Gallery or my testimony about it as an expert witness in the New York trial you referred to in your letter. The Gallery is linked to from many sources, including the Electronic Frontier Foundation and USA Today. It is listed on my curriculum vitae, and in my online list of scholarly works at http://www.cs.cmu.edu/~dst/bib.html I would like to know if it is the intent of the MPA to exert editorial control over scholarly publications by computer science faculty that deal with DeCSS, and if so, exactly which sort of publications will the MPA permit in the future, and which sort will result in legal threats such as your letter of yesterday. Thank you for your time. Sincerely, Dr. David S. Touretzky Principal Scientist